What are the commencement dates for the LPPM Responsible Sourcing Programme?
The LPPM Responsible Sourcing Programme is mandatory from 1st January 2020. In order to avoid any doubt this means that any refiner whose financial year ends on 31st December 2019 will have to complete an audit within the first quarter of 2020. This is the first reference date.
However we strongly recommend that refiners should perform an introductory audit in 2019 in order to gain experience and understanding of the processes. During this introductory period non-conformances will not be penalised, excepting of course any illegal activities that may arise.
Should one report be produced for Pt + Pd, or 2 different like for Au+Ag?
One report - Pt and Pd are subject to the same guidance rules and generally the refiners and their markets are closely linked in most aspects.
When defining the number of transactions to be checked, are Pt and Pd transactions to be evaluated separately? Or can all transactions be pooled together and tested without considering which metal is involved?
Similar to the above, transactions should be evaluated according to the level of sampling not by individual metal
If the first audit to be performed in 2019 is a “reasonable assurance” (full audit), can the first mandatory audit performed in 2020 be a “limited assurance” one?
Yes, we believe so, unless something extraordinary arises after the first audit. However compliance should take it on a case by case basis
What is the threshold to define what a Pt or Pd supplier is? For example, if a customer provides material containing 99% of Au and 1% of Pt, is that also a Pt supplier and a Pt transaction?
We would suggest that if the Pt and/or Pd content exceeds say 10% of the refinable material content, then a Pt/Pd audit for that material as well as Au or Ag
Does a current listed refiner have to use an auditing body on the LPPM's Approved Service Provider list?
Are there any costs associated with becoming an LPPM Approved Service Provider?
No, all we ask is that you complete the application form and submit it to the LPPM for consideration.
What competencies and skills does an Auditor need to fulfil in order to become an Approved Service Provider?
A description of the auditor competencies and skills requirements can be found in section 1.4 of the LPPM’s Third Party Audit Guidance. Available to download in the Toolkit section on the website.
How does the LPPM Responsible Platinum and Palladium affect potential GDL applicants?
Any Refiner applying to be an LPPM Good Delivery accredited Platinum and/or Palladium Refiner is required to implement the LPPM Responsible Platinum and Palladium Guidance and pass an audit prior to becoming a member of the LPPM Good Delivery List. All GDL Applicants must use an auditor on the LPPM's Approved Service Provider List.
What is the procedure for becoming an Approved Service Provider?
Once the auditor submits their application form the LPPM’s Compliance Team will review the application and inform the applicant of their success or failure. This will normally take around 1 month.
What is the annual review procedure for Approved Service Providers?
The LPPM Compliance Team will review the Approved Service Provider list on an annual basis. The LPPM Compliance Team will ask the listed auditing bodies if anything has change within their organisation or operations since their original application. If nothing has changed, no action is required. Supporting evidence in the form of documentation will be required if substantial changes have been made. The LPPM Compliance Team will then decide if the auditing body can remain on the list.
Where a refiner has been removed from the Good Delivery List due to failure to adhere to the LPPM Responsible Platinum and Palladium Guidance, when are they able to re-apply for Good Delivery Status?
A refiner has to wait five years before submitting their application.
Is the LPPM Toolkit compulsory for Responsible Platinum and Palladium Guidance audits?
The LPPM Toolkit is intended for use as a guide to how refiners may implement the Responsible Platinum and Palladium Guidance. Refiners may adopt their own documentation and checklists as part of their controls and procedures.
What does it mean if the refiner’s certificate has expired, but their name still appears on the Current Platinum and/or Palladium List?
If a refiner’s certification appears to be expired but they remain on the Platinum and/or Palladium List, the refiner’s audit is in progress. They remain Good Delivery.
What happens once an audit report has been submitted? How long does it take to become accredited?
Once your audit report has been received, it will take approximately one month before the Compliance Review Panel provides an official response. This process will take longer if your audit requires a Corrective Action Plan to be submitted.
We are experiencing delays with submitting the audit report. What will happen to our accreditation?
Deadline extensions may be granted under exceptional circumstances. You are advised to get in touch with LPPM as quickly as possible in advance of the deadline.
How does mutual recognition of third party refiner due diligence audits work?
LPPM Good Delivery List refiners will be required to perform audits against the Responsible Platinum and Palladium. Supporting documentation from audits under other industry schemes may be submitted as part of the refiner’s audit deliverables.